The proposals come hot on the heels of the accelerated payments and follower notice provisions in the Finance Act 2014, which raised the stakes for determining which schemes will be caught in the net.

Most of the suggestions concern ways to tighten the net around arrangements caught by the disclosure of tax avoidance schemes (DOTAS), which are now subject to the upfront payments. Other ideas include bringing IHT and VAT avoidance within the scope of DOTAS.

Between now and the consultation deadline on 23 October include:

Removing the ‘grandfathering’ rule that omits schemes that are similar to arrangements made before 1 August 2006

Widening the “hallmarks” of DOTAS-reportable schemes, for example to include a list of involving loans, derivatives and other financial products that give rise to a tax advantage

Increased penalties for scheme users who do not notify a DOTAS scheme reference number in the correct box on the tax return.

Baker Tilly’s David Heaton took a dim view of the VAT proposals in this week’s Tax Brief, arguing that VAT is covered by separate EU directive. “It strikes us that in light of subsequent VAT anti-avoidance legislation and developing case law, we don’t actually need listed VAT schemes any more. Extending DOTAS to treat VAT avoidance the same way as income and corporation tax, CGT, NICs, SDLT, IHT and ATED “would just be plain daft”, he argued.

Other documents released in HMRC’s summer consultation surge include:

Capital gains tax - Legislating extra-statutory concession D33 Proposals to increase to £1m the limit on the amount of compensation automatically exempt, with amounts in excess of £1m chargeable to CGT, and to legislate the relief for personal compensation or damages (HMRC). Launched 31 July; Closes 15 September

Employee travel and subsistence review A review of the rules underlying tax treatment of travel and subsistence expenses, announced at Budget 2014 in response to an Office of Tax Simplification report on employee benefits and expenses (HM Treasury). Launched 31 July; Closes 23 October

VAT mini one stop shopTechnical consultation on amendments to VAT regulations to allow for introduction of the mini one stop shop (MOSS). From January 2015 suppliers of digital services will be required to account for VAT in the member states where their customers are located. MOSS will allow businesses to register in one member state only and submit a single VAT return and payment payment for all cross border supplies of digital services (HMRC) . Launched 7 August; Closes 26 August